Williams v. State
290 Ga. 24
| Ga. | 2011Background
- Williams was arrested on unrelated drug and firearm charges in 2004 and remained detained.
- Two murder victims were found in Fulton County; Williams was later held for those murders starting November 5, 2005.
- Williams was denied bond on the murder charges on December 6, 2005 and remained incarcerated.
- A 14-count Fulton County indictment for the double murders was returned on August 22, 2006.
- Between 2005 and 2010 Williams had multiple public defenders; he filed a motion for discharge and acquittal on July 9, 2010.
- The Fulton County Superior Court denied the motion on August 27, 2010, after a four-year pretrial delay.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the delay was presumptively prejudicial | Williams asserts the delay from indictment to motion breached speedy-trial rights. | State contends delay was presumptively prejudicial and then weighed under Barker factors. | Delay was presumptively prejudicial; court proceeded to Barker factors. |
| Reasons for the delay | Delay served to hamper defense or gain tactical advantage. | Delay arose from case complexity, active docket, and defense changes, not deliberate tactics. | Delay attributed to benign/complexity factors weighed in defendant's favor. |
| Assertion of the right to a speedy trial | Williams timely asserted the right as the case neared trial. | He waited 57 months after arrest and after scheduling multiple trials to raise the issue. | Assertion occurred late; weight attributed heavily against Williams. |
| Prejudice from the delay | Prolonged incarceration and potential impairment of defense prejudice Williams. | No oppressive incarceration or significant impairment shown; defense witnesses not shown diligently unavailable. | Prejudice weighed benignly against Williams; no abuse of discretion found. |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (balancing four-factor test for speedy-trial claim)
- Fallen v. State, 289 Ga. 247 (Ga. 2011) (weighing factors; delay-informed deference to trial court)
- Ruffin v. State, 284 Ga. 52 (Ga. 2008) (presumptive prejudice threshold and Barker framework)
- Jones v. State, 284 Ga. 320 (Ga. 2008) (clarifies calculation of prejudicial delay and admissibility concerns)
- Weis v. State, 287 Ga. 46 (Ga. 2010) (workload and incidental delays weighed lightly against State)
- Sweatman v. State, 287 Ga. 872 (Ga. 2010) (extraordinarily heavy docket as a factor in prejudice)
- Scandrett v. State, 279 Ga. 632 (Ga. 2005) (timeliness of assertion and prejudice considerations)